COVID-19 Update
March 25, 2020

Suspension of Community Outings and Home Visits 
After several discussions with the Care Coordination Organizations and the Provider Associations, OPWDD has directed the temporary suspension of individual community outings and home visits. This policy takes effect March 25 at 5 p.m. The directive addresses individuals who are currently away on home visits and restrictions on community outings and home visits. In the limited circumstances where community activities occur, OPWDD expects that providers will follow the New York State Department of Health (NYS DOH) Guidance When Enjoying the Outdoors. Chapters should ensure that all individuals supported, families and staff are aware of this policy change. As with the March 18 suspension of visitation policy, Chapters should ensure that these policies are posted to their website and social media pages. A template letter and sample social media post can be found here to assist Chapters in meeting these notification requirements. 
OPWDD Billing Guidance 
OPWDD has published temporary billing guidance for providers of day services (explicitly Group Day Habilitation, Prevocational and Day Treatment services). The billing guidance is specific to dates of service beginning March 18 through March 31. OPWDD is currently seeking an extension of the billing flexibility beyond March 31.
Billing is based on the routine program schedule for day services for individuals who were actively receiving day services as of March 18. This guidance should be provided immediately to Chapter billing departments with procedures updated to reflect the submission of retainer day payments. OPWDD recognizes that providers may not have service documentation as required in the governing ADMs for Group Day Habilitation, Prevocational and Day Treatment services. As was discussed in OPWDD's Day Services Guidance and Implementation webinar, at a minimum, providers should document the start and stop times of service delivery, as well as a description of the service delivered. A recording of the webinar will be published on the Managed Care Community of Practice (MCCOP) website.
A recording of OPWDD's General Overview of Comprehensive COVID-19 Response webinar presented on March 23 can be found here.

Disclosure of COVID-19 Information to First Responders 
The U.S. Department of Health and Human and Services (DHHS) Office for Civil Rights (OCR) published guidance on disclosures of COVID-19 information to first responders without an individual's authorization.
The guidance explains the circumstances under which a covered entity may disclose Protected Health Information (PHI) such as the name or other identifying information about individuals, without their HIPAA authorization, and provides examples including:
  • when needed to provide treatment,
  • when required by law,
  • when first responders may be at risk for an infection, and
  • when disclosure is necessary to prevent or lessen a serious and imminent threat.
This guidance clarifies the regulatory permissions that covered entities may use to disclose PHI to first responders and others so they can take extra precautions or use appropriate personal protective equipment (PPE). The guidance also includes a reminder that generally, covered entities must make reasonable efforts to limit the PHI used or disclosed to the "minimum necessary" to accomplish the purpose for the disclosure.
Chapter quality and compliance staff should take special note of this guidance and ensure that staff who may come into contact with first responders are aware of what information they may share regarding COVID-19.

Guidance for Family Care Providers 
OPWDD published revised interim guidance to Family Care providers. This is an update to the March 20 guidance. The revisions are specific to the reporting and notification requirements for OPWDD providers, beginning on page four. The revision explicitly identifies that reports are not considered reports of abuse/neglect, significant incidents, or notable occurrences, and that they are being used to support public health efforts.
This document is intended to assist OPWDD Family Care Providers in the prevention and management of COVID-19. Reporting and notification requirements for any cases of quarantine or isolation is also included.

This and all related updates will be cataloged on The Arc New York COVID-19 Resource Page  for future reference. Please contact us if you have questions regarding any of this information.

Josh Christiana , Associate Executive Director for Quality, Compliance & Chapter Relations

This email was sent to:
  • President Jack Kowalczyk 
  • Board of Governors 
  • Chapter Presidents
  • Executive Directors 
  • Chief Operating Officers
  • Chief Financial Officers  
  • HR Directors 
  • PR Directors 
  • Quality & Compliance Staff 
  • Joint Committee on Quality & Compliance 
  • State Office Staff